Summary

DESTRUCTION OF THE U.S. CHEMICALSTOCKPILE

The Department of Defense, through the Assembled Chemical Weapons Alternatives (ACWA) program, is currently in the process of constructing two full-scale pilot plants at the Pueblo Chemical Depot in Colorado and the Blue Grass Army Depot in Kentucky to destroy the last two remaining inventories of chemical weapons in the U.S. stockpile. Destruction of this stockpile, originally comprising over 31,000 tons of chemical agents stored at eight chemical weapons depots in the continental United States and on Johnston Island in the Pacific Ocean (southwest of Hawaii), has been ongoing for two decades, and is being performed in accordance with requirements of the Chemical Weapons Convention treaty, to which the United States is a signatory. Approximately 10 percent of the original stockpile is stored at the Pueblo Chemical Depot and the Blue Grass Army Depot, with approximately 90 percent stored at sites being served by the U.S. Army Chemical Materials Agency (CMA) disposal facilities. As of January 12, 2011, the CMA had destroyed 83 percent of the stockpile being treated at its facilities.1

Disposal operations at the six other continental U.S. sites and Johnston Island, managed by the CMA, either have been completed or are nearing completion. The disposal facilities at these sites were either based on incineration technology to destroy the chemical agents and associated energetics (propellants and/or explosives) or used chemical neutralization (hydrolysis) to destroy nerve and mustard agents stored in bulk containers.

In contrast, the Pueblo and Blue Grass Chemical Agent Destruction Pilot Plants (PCAPP and BGCAPP) will use neutralization technology to destroy the agents that are contained in various types of assembled chemical munitions—that is, rockets, projectiles, and mortar rounds. Consequently the processing equipment employed at PCAPP and BGCAPP will be newer or of different design than the equipment at the other disposal facilities. These pieces of process equipment are referred to as first-of-a-kind (FOAK) equipment. The FOAK equipment the committee believes could pose the most significant challenges to operations at PCAPP and BGCAPP is described in Table S-1.

For reasons such as the use of FOAK equipment and, more broadly, in recognition of the need to conscientiously adhere to congressional mandates that destruction of chemical agent and munitions be executed with maximum protection for workers, the public, and the environment, the Program Manager for Assembled Chemical Weapons Alternatives requested that the National Research Council (NRC) undertake a study to guide the development and application of process safety metrics for PCAPP and BGCAPP. Another reason for requesting this report was the NRC report issued in 2009 Evaluation of Safety and EnvironmentalMetrics for Potential Application at Chemical AgentDisposal Facilities, which responded to a request by the CMA for recommendations on additional metrics

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Summary
DESTRUCTION OF THE U.S. CHEMICAL agents and associated energetics (propellants and/or
STOCKPILE explosives) or used chemical neutralization (hydroly-
sis) to destroy nerve and mustard agents stored in bulk
The Department of Defense, through the Assembled containers.
Chemical Weapons Alternatives (ACWA) program, is In contrast, the Pueblo and Blue Grass Chemical
currently in the process of constructing two full-scale Agent Destruction Pilot Plants (PCAPP and BGCAPP)
pilot plants at the Pueblo Chemical Depot in Colorado w ill use neutralization technology to destroy the
and the Blue Grass Army Depot in Kentucky to destroy agents that are contained in various types of assembled
the last two remaining inventories of chemical weap- chemical munitions—that is, rockets, projectiles, and
ons in the U.S. stockpile. Destruction of this stockpile, mortar rounds. Consequently the processing equipment
originally comprising over 31,000 tons of chemical employed at PCAPP and BGCAPP will be newer or of
agents stored at eight chemical weapons depots in the different design than the equipment at the other dis-
continental United States and on Johnston Island in the posal facilities. These pieces of process equipment are
Pacific Ocean (southwest of Hawaii), has been ongoing referred to as first-of-a-kind (FOAK) equipment. The
for two decades, and is being performed in accordance FOAK equipment the committee believes could pose
with requirements of the Chemical Weapons Conven- the most significant challenges to operations at PCAPP
tion treaty, to which the United States is a signatory. and BGCAPP is described in Table S-1.
Approximately 10 percent of the original stockpile For reasons such as the use of FOAK equipment and,
is stored at the Pueblo Chemical Depot and the Blue more broadly, in recognition of the need to conscien-
Grass Army Depot, with approximately 90 percent tiously adhere to congressional mandates that destruc-
stored at sites being served by the U.S. Army Chemi- tion of chemical agent and munitions be executed with
cal Materials Agency (CMA) disposal facilities. As of maximum protection for workers, the public, and the
January 12, 2011, the CMA had destroyed 83 percent environment, the Program Manager for Assembled
of the stockpile being treated at its facilities.1 Chemical Weapons Alternatives requested that the
Disposal operations at the six other continental National Research Council (NRC) undertake a study
U.S. sites and Johnston Island, managed by the CMA, to guide the development and application of process
either have been completed or are nearing completion. safety metrics for PCAPP and BGCAPP. Another
The disposal facilities at these sites were either based reason for requesting this report was the NRC report
on incineration technology to destroy the chemical issued in 2009 Evaluation of Safety and Environmental
Metrics for Potential Application at Chemical Agent
Disposal Facilities, which responded to a request by
1See http://www.cma.army.mil/home.aspx for updated informa -
the CMA for recommendations on additional metrics
tion as the program progresses.
1

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2 PROCESS SAFETY METRICS AT THE BLUE GRASS AND PUEBLO CHEMICAL AGENT DESTRUCTION PILOT PLANTS
TABLE S-1 First-of-a-Kind Equipment and Processes That Could Pose Significant Challenges for PCAPP and
BGCAPP
FOAK Equipment Site(s) Function Notes
Rocket cutting machine BGCAPP To separate rocket motors from This is an entirely new piece of
(RCM) the warhead. equipment.
Linear projectile mortar BGCAPP To disassemble projectiles This is a new unit that replaces the
disassembly (LMPD) PCAPP and mortars and remove their PMD machine used at the baseline
machine bursters. incineration sites operated by CMA.
Munitions washout station BGCAPP To remove the burster well This is an entirely new piece of
(MWS) PCAPP from projectiles, drain the equipment. It replaces the PMD
chemical agent, and wash out machine used at the baseline
any agent residues. incineration sites operated by CMA.
Energetics batch hydrolyser BGCAPP To neutralize energetics and This is an entirely new piece of
(EBH) any chemical agent in the metal equipment.
parts of the rockets and fuzes
from projectiles.
Metal parts treater (MPT) BGCAPP To decontaminate projectile This is an entirely new piece of
bodies and secondary waste equipment.
by heating to over 1000°F for
more than 15 minutes.
Munitions treatment unit PCAPP To decontaminate projectile This is an entirely new piece of
(MTU) bodies and secondary waste equipment.
by heating to over 1000°F for
more than 15 minutes.
Supercritical water BGCAPP To treat agent and energetics This is an entirely new piece of
oxidation (SCWO) hydrolysates before releasing equipment and process.
them for final disposal.
Immobilized-cell PCAPP To treat mustard hydrolysate This is an entirely new piece of
bioreactors (ICBs) before releasing it for final equipment and process.
disposal.
that could further improve the safety and environmental American Institute of Chemical Engineers, etc.) that could
be used by ACWA.
programs at those sites.
The statement of task for the Committee to Assess
As previously indicated, both PCAPP and BGCAPP
Process Safety Metrics for the Blue Grass and Pueblo
will use chemical neutralization technology instead
Chemical Agent Destruction Pilot Plants (the commit-
of incineration to destroy chemical agents and, in the
tee) is the following:
case of BGCAPP, to destroy certain energetics. Neu-
tralization involves the hydrolysis of chemical agent
The National Research Council will establish an ad hoc
and energetics using hot water for mustard agent and
committee to:
caustic for nerve agent and energetics. PCAPP plans
• eview and evaluate plans for the use of process safety
R to ship the energetics removed from munitions for
metrics to be employed at the two Assembled Chemical
disposal offsite and will use biotreatment to destroy
Weapons Alternatives (ACWA) pilot plant facilities,
the products of mustard agent neutralization, known as
• xamine and assess the process safety metrics used in
E
hydrolysate. BGCAPP will use neutralization followed
commercial and industrial operations for potentially ap-
by the treatment of the resultant agent and energetics
plicable process safety metrics, and
• ssess new initiatives at national organizations (i.e.,
A

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3
SUMMARY
BACKGROUND INFORMATION RELATED TO
hydrolysates by supercritical water oxidation.2 Imple-
PROCESS SAFETY METRICS
mentation of these primary and secondary destruction
methods also entails numerous ancillary processes and
There are two types of process safety metrics: lead-
activities—for example, munitions disassembly and
ing and lagging.3 Defining appropriate and effective
waste management, which in turn require the use of
leading and lagging process safety metrics has been
additional FOAK equipment and processing.
a subject of great interest in recent years, particularly
The term FOAK implies the use of new technologies
in the chemical and petroleum industries, since those
or new applications of existing technologies that could
industries handle or produce reactive, toxic, and flam-
be problematic with respect to functionality, reliabil-
mable materials that, if released, can cause multiple
ity, availability, and maintainability. This means that
fatalities and/or injuries and have significant envi-
adjustments ranging from procedural modifications to
ronmental consequences. Further details on efforts
varying degrees of redesign might be required as such
to formalize and implement industrywide approaches
equipment is developed, tested, and integrated into
to process safety metrics are provided in Chapter 4.
actual agent processing operations. One example of
A good example of a lagging process safety metric
FOAK equipment, the linear projectile mortar disas-
that has been in use for over a decade is the number
sembly machine, is undergoing testing at the Annis-
of unplanned major chemical or energy releases. This
ton Chemical Agent Disposal Facility. As a result of
metric has included unintended releases of hazardous
this testing, 164 specific operating criteria have been
chemicals that exceed the threshold quantity listed in
reviewed, 20 documented lessons learned will be
40 CFR 302.4, which designates CERCLA4 hazardous
applied to the design and operation of the system at
substances or events that result in serious injury or
PCAPP, and more than 110 significant code changes
damages in excess of $25,000.
have been identified. Although not all FOAK equip-
While many of the processes that will be employed
ment will be tested in an operational setting prior to
for the disposal of chemical agent and munitions at
systemization, as the linear projectile mortar disassem-
PCAPP and BGCAPP are fundamentally different
bly machine has been, laboratory testing and evaluation
from those used at the other chemical agent disposal
of all FOAK equipment is performed to identify issues
facilities, some similarities do exist with the processes
and needed adjustments before the equipment is placed
that have been employed at those sites. The committee
in operation.
believed that evaluating the experience with process
PCAPP and BGCAPP will both undergo preop -
incidents at those other sites could prove useful and
erational systemization before starting actual agent
would offer guidance on what process safety metrics
disposal operations. Systemization involves progres-
might be useful for PCAPP and BGCAPP. The com-
sive testing—from the demonstration of components
mittee further believed that an analysis of relevant
to subsystems to the entire system, using surrogate
chemical events at those sites could provide insights
munitions—to bring each system to its fully operational
on the process steps and operational systems that are
design function. Both facilities will follow a progres-
most subject to failure, and might identify opportunities
sion of steps consisting of the installation of process
where the use of leading and lagging metrics could help
equipment, integration of process equipment, and
to prevent failures.
overall plant operation using agent surrogates instead of
The NRC Committee on Evaluation of Chemical
actual chemical agent. During this phase of the project,
Events at Army Chemical Agent Disposal Facilities
the systems used to operate the plant will be tested and
(the chemical events committee) examined documen-
configured.
tation on all of the chemical events that had occurred
since commencement of destruction operations through
the end of 2001 and issued its report, Evaluation of
Chemical Events at Army Chemical Agent Disposal
3“Leading metric” and “lagging metric” are defined in Appendix A.
2Neutralization 4CERCLA is the Comprehensive Environmental Response, Com-
was used to destroy the chemical agents at two
other sites, at Aberdeen Proving Ground, Maryland, and Newport, pensation, and Liability Act, commonly known as Superfund; 40
Indiana. These two sites, however, had only bulk agent stored in CFR 302.4 lists dangerous chemicals and gives threshold quantities
ton containers, not assembled munitions. for the purpose of defining a process safety incident.

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4 PROCESS SAFETY METRICS AT THE BLUE GRASS AND PUEBLO CHEMICAL AGENT DESTRUCTION PILOT PLANTS
Facilities, in 2002. The present committee reviewed • quipment malfunction. This was the second most
E
that report to identify which of the events could be prevalent causal factor at other chemical agent
classified as process incidents. It also requested an disposal facilities, approximately 26 percent of
update on process-related chemical events from all cur- the total. While the definition of equipment mal-
rently operating sites and from the sites that completed function used at these facilities did not include
destruction after 2001. Significantly, the frequencies design deficiencies, it should be noted that design
of incident types, activities, and causal factors for deficiencies caused equipment malfunctions in
process-related chemical events since 2001 mirror some instances. Equipment malfunctions and
those that were noted in the 2002 Chemical Events design deficiencies together were involved in
report. From these data, it appears that the frequency approximately 31 percent of the total incidents
and type of factors that cause process safety events are reviewed. Conducting design audits and basing
independent of the type of facility (neutralization or metrics on the results could assist in finding
incineration), the type of chemical weapon (mustard design deficiencies before they cause an equip-
agent or nerve agent), or how the agent is stored (in ment malfunction or other process incidents or
assembled munitions or bulk). Consequently, PCAPP upsets. A system of process safety-critical equip-
and BGCAPP can reasonably be expected to experience ment inspections is key to minimizing equipment
the same types of events that have similar causal fac- malfunctions.
tors. However, because the processes to be employed • uman factors (human error, mindset, and
H
at PCAPP and BGCAPP are unique, and FOAK equip- improper technique). H uman factors, which
ment will be used extensively, it may be reasonable to include the three causal factors listed in the paren-
expect more events at the outset and a possible shift in theses above, altogether accounted for approxi-
the frequency of causal factors. For example, design mately 37 percent of the causal factors. Metrics
deficiencies might be more prevalent in new facilities derived from training activities and job cycle
with new equipment, processing steps, and unit opera- checks could be useful in developing actions to
tions than in older or second-generation facilities using mitigate these types of causal factors and to iden-
proven, refined technologies and processes. Some of tify areas where annual or more frequent periodic
the personnel who will systemize and operate PCAPP training should be improved or changed.
and BGCAPP will come from operating chemical • ommunications deficiencies. This causal factor
C
demilitarization facilities, providing an experience base made up approximately 4 percent of the total.
in chemical demilitarization at the two sites. These types of deficiencies are not typically
documented until after a failure, but they should
be considered as integral to a full complement of
DERIVING PROCESS SAFETY METRICS
process safety metrics. Among the possibilities
RELEVANT TO PCAPP AND BGCAPP
are audits of communications systems (active
The committee’s examination of causal factors and passive) and documenting communications
related directly to earlier experience with chemical failures.
agent and munition destruction provides an excellent
basis for the development of process safety metrics at Based on experience, a number of leading metrics
PCAPP and BGCAPP. Some key causes of process recommended in the documents of the Center for
safety incidents at former and currently operating Chemical Process Safety and the American Petroleum
chemical agent disposal facilities identified from that Institute and discussed in Chapter 4 could also be rel-
experience are discussed below. evant to PCAPP and BGCAPP. These leading metrics
include process safety near-miss events, closure of
action items, completion of emergency response drills,
• tandard operating procedure (SOP) deficiencies.
S
SOP deficiencies were the most prevalent causal management of change, and metrics related to other
factor identified, approximately 27 percent of the management systems.
total. For PCAPP and BGCAPP, developing and Managerial leadership is responsible for setting the
implementing metrics that enable early identifica- tone and articulating performance expectations in an
tion and avoidance of deficiencies in SOPs could organization. When process safety metrics are set for
be very useful. an organization, the operation’s line leadership must

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5
SUMMARY
set performance milestones and regularly review the ing causal factors similar to those experienced at the
operation’s performance against those milestones with Chemical Materials Agency sites. Also, there may be
the organization’s managerial leadership. Furthermore, an increase in the frequency of events and a shift in the
the chemical, petroleum, and related industries have relative frequency of causal factors.
learned that maintaining a staff of trained process
Finding 4-1. At the present time, there is no defini-
safety professionals is vital to the avoidance of pro-
cess incidents. Several other industries—for example, tion of a process safety incident other than “release of
the nuclear power industry—and government facili- agent” within the Assembled Chemical Weapons Alter-
ties engaged in hazardous processes have been hiring natives program. Establishing or adopting a common
full-time staff members to develop and monitor their definition for process safety incidents would improve
process safety programs, although they have not done consistency of reporting and sharing of lessons learned
so as quickly as the chemical and petroleum industries. within the program.
Recommendation 4-1. The Program Manager for
FINDINGS AND RECOMMENDATIONS
Assembled Chemical Weapons Alternatives should
All of the committee’s findings and recommenda- adopt the definitions of Tier 1-4 process safety events
tions are listed below. They are numbered according to in Recommended Practice 754, Process Safety Perfor-
their order in the chapters in which they appear. mance Indicators for the Refining and Petrochemical
Industries, a joint recommendation of the American
Finding 2-1. Because of the unique nature of the pro- National Standards Institute and the American Petro-
cesses at the Pueblo Chemical Agent Destruction Pilot leum Institute, with the exception that the reporting
Plant and the Blue Grass Chemical Agent Destruction threshold for chemical agents should be defined as any
Pilot Plant and the extensive use of first-of-a-kind unintended release.
equipment, the use of both leading and lagging pro-
Finding 4-2. D eveloping metrics for the Pueblo
cess safety metrics will be important in achieving the
congressional mandate to safely destroy the chemical Chemical Agent Destruction Pilot Plant and the Blue
weapons stockpiles at the respective sites. Systemiza- Grass Chemical Agent Destruction Pilot Plant based on
tion affords an excellent opportunity to implement and operating experience at other chemical agent disposal
evaluate leading and lagging process safety metrics. facilities would help to avoid failures that lead to pro-
cess safety incidents.
Recommendation 2-1. During systemization, the Recommendation 4-2. The Program Manager for
Program Manager for Assembled Chemical Weapons Assembled Chemical Weapons Alternatives should
Alternatives should develop and implement extensive take into account the causal factors in past process
process safety metrics that can be evaluated for rel- safety incidents at chemical agent disposal facilities
evance and utility. Metrics that are found to be mean- when devising process safety metrics for the Pueblo
ingful should be carried forward to operations. While Chemical Agent Destruction Pilot Plant and the Blue
both leading and lagging metrics should be developed Grass Chemical Agent Destruction Pilot Plant.
and implemented to the extent possible, both the Pueblo
Finding 4-3. Many process safety metrics that could be
Chemical Agent Destruction Pilot Plant and the Blue
Grass Chemical Agent Destruction Pilot Plant should used by the Pueblo Chemical Agent Destruction Pilot
emphasize developing leading metrics to guide them in Plant and the Blue Grass Chemical Agent Destruction
process safety management. Pilot Plant are available to the public, including those
in the list of metrics in the Center for Chemical Process
Finding 3-1. The causal factors involved in past events Safety publication Guidelines for Process Safety Met-
at chemical agent disposal facilities are not process rics. These metrics could complement process-specific
specific. Consequently, the Pueblo Chemical Agent metrics developed at the respective sites.
Destruction Pilot Plant and the Blue Grass Chemi-
Recommendation 4-3. The Pueblo Chemical Agent
cal Agent Destruction Pilot Plant can reasonably be
expected to experience the same types of events hav- Destruction Pilot Plant and the Blue Grass Chemical

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6 PROCESS SAFETY METRICS AT THE BLUE GRASS AND PUEBLO CHEMICAL AGENT DESTRUCTION PILOT PLANTS
Recommendation 4-5. The Program Manager for
Agent Destruction Pilot Plant should adopt the met-
rics listed below and develop process-specific leading Assembled Chemical Weapons Alternatives and site
and lagging metrics. The ACWA program should also management should perform periodic reviews of pro-
consider a metric associated with emergency planning cess safety metrics utilized at PCAPP and BGCAPP
and response as well as published lists of process safety and implement action plans as appropriate to drive
metrics and should adopt those that appear to be of continuous improvements.
value to these sites.
Finding 4-6. The chemical and petroleum industries
• ount of process safety near-miss events.
C have found it very beneficial to have employees on
• raining records such as validation of job cycle
T staff with process safety expertise. These individuals
checks and completion of training, including partner with senior management and are accountable
refresher training. for monitoring industry best practices in process safety
• ob procedures:
J and for implementing those that are applicable within
–Statistics on whether a procedure was used and, their facilities. These individuals are also tasked with
if it was, was the procedure the correct one? assisting in embedding process safety into the organi-
–Validation that procedures are current and zation’s culture by organizing and leading grassroots
accurate. process safety teams while reviewing outcomes and
• tatistics on the closure of action items.
S metrics with management.
• ercent of inspections of safety-critical equip-
P
Recommendation 4-6. The Program Manager for
ment completed on time.
• ercent of sampled management of change
P Assembled Chemical Weapons Alternatives should
instances that met all requirements and quality maintain process safety expertise at the programmatic
standards. level to ensure effective implementation of process
safety metrics. To be successful, process safety experts
Finding 4-4. The United Kingdom Health and Safety must partner with and be supported by management.
Executive’s Health and Safety Guidance 254 (UK HSE
Finding 4-7. There are a number of resources that the
HSG 254) provides a methodology to develop process-
specific leading and lagging metrics. Program Manager for Assembled Chemical Weapons
Alternatives can use to learn about best practices for
Recommendation 4-4. Given that the two facilities process safety management in the chemical and petro-
are pilot facilities and make extensive use of first-of-a- leum industries. Process safety technology conferences
kind equipment, the Pueblo Chemical Agent Destruc- such as the American Institute of Chemical Engineers’
tion Pilot Plant and the Blue Grass Chemical Agent annual Global Congress of Process Safety and others
Destruction Pilot Plant should review their hazard hosted by organizations such as the Center for Chemi-
assessment documents to identify and consider imple- cal Process Safety and the Mary Kay O’Connor Pro-
menting leading or lagging metrics specific to each cess Safety Center provide ongoing programming on
piece of equipment or area of the plant. These efforts process safety and the identification of best practices.
should follow the approach outlined in the United
Recommendation 4-7. The Program Manager for
Kingdom’s Health and Safety Executive Health and
Safety Guidance 254 (UK HSE HSG 254), Developing Assembled Chemical Weapons Alternatives should
undertake a review of best practices in process safety
Process Safety Indicators: A Step-by-Step Guide for
Chemical and Major Hazard Industries. management, especially in the chemical and petroleum
industries. These practices are described in the Center
Finding 4-5. A formalized mechanism for a periodic for Chemical Process Safety book Guidelines for Risk
review of process safety metrics by management is Based Process Safety. Those that are applicable should
an established best practice in industry to verify that be incorporated into the Pueblo and Blue Grass Chemi-
management is involved and can drive continuous cal Agent Destruction Pilot Plants.
improvement.